Renewable Energy - CMS · SWOT analysis of Hungarian market Strengths • The share of renewable...

Renewable EnergyA solid network for a solid business

2008

The environment is now recognized as afundamental commercial issue affectingall businesses and industry sectors,amongst which the energy sector ismost directly affected.

Introduction

CMS Cameron McKenna LLP, Mitre House, 160 Aldersgate Street, London EC1A 4DD

© CMS Cameron McKenna LLP 2008

We at CMS Cameron McKenna are continuously expandingour capabilities to work with clients to create sustainableenergy supplies from renewable energy sources (RES), and tothis end we have brought together a team of energy,projects, banking and environmental legal experts to providea comprehensive advice on a range of issues, including, legaland regulatory framework affecting renewable energy,development of renewable energy projects, emissionstrading, CDM, CCS and JI projects.

CMS Cameron McKenna is the founding member of CMS,with well-established full-service offices in eight key businesscentres of Central and Eastern Europe. CMS aims to be theleading organisation of independent European law and taxfirms of choice for organisations based in, or looking tomove into, Europe. We are committed to quality, theinterests of our clients, and the development of our people.

Our focus is on providing efficient, commercial legal and tax solutions aimed at helping you achieve your businessobjectives.

CMS Cameron McKenna in Central and Eastern Europe isunique for its combination of local knowledge andinternational experience, which means that we can addressboth domestic and cross-border issues. We build strong, longterm relationships, instead of just focusing on one-timetransactions. Our partners are "hands on", veryapproachable and accessible. Finally, our clients praise ourpro-active approach to alerting them to issues that theirbusinesses might have to face.

Below we would like to present a snapshot of the factorsaffecting renewable generation projects, which would be ofparticular interest to investors, developers and lenders in theindividual CEE countries where we are present. We would behappy if this document provides you with answers to someof the questions you might have about the investmentclimate in the renewable sectors of the region.

Most of the countries are aiming to significantly increase the share of energy generated byrenewable sources. In particular, the EU member states, have set more challenging targetsthan other countries in the region by the so called 3x20% objectives established in March2007 (20% of greenhouse gas reduction, 20% of renewable energy share in final energyconsumption, and increase of the energy efficiency by 20% by the year 2020).

SWOT analysis ofBulgarian market

Strengths• Significant RES potential especially water, wind,

solar and biomas.

• 12 years PPA are available and there is anobligatory offtake by the National ElectricityCompany (NEC) or electricity distributioncompanies, and grid connection.

• EU funds available for such projects.

• National target for RES to increase over the years(8% by 2010, 12% by 2015 and 20% by 2020).

• Preferential offtake price.

• Independent regulatory body (SEWRC).

• Green certificates are likely to be introduced after 2011.

• Special support by the investment supportlegislation.

Weaknessess• Bureaucratic and slow procedures – multiple

entities involved in decision-making process and ascounter-parties; Ministry of Economy and Energy,SEWRC, Energy Efficiency Agency, NationalElectricity Company, electricity distributioncompanies, etc.

• Increasing costs of land (wind projects); slowdevelopments of the biomas and PV opportunities.

• Unwillingness to undertake interconnections,mainly by NEC; investments by the electricitydistribution companies are only supported partiallyby the SEWRC (Energy Regulator).

Opportunities• New Law on renewable and alternative energy

sources and bio fuel (2007) and Ordinances(pending).

• New Energy Efficiency Act expected later in 2008.

• Availability of EU structural and cohesion funds.

• Privatization of some mid-sized hydro power plantsexpected in 2009.

Threats• The national transmission grid needs significant

upgrades to support all the announced REScapacities that are to be built over the next years.

• Lack of effective cooperation and streamlinedadministrative procedures.

• Likelihood of change in the support mechanismsfor RES after 2011.

• Ecological considerations – many projects weredelayed and even cancelled for ecologicalconsiderations – migration of birds, Natura 2000Program, etc. Environmental Impact Permit isrequired.



Key assignments• Advising Iberdrola Renovables on the acquisition of a

74MW wind farm project in northern Bulgaria. Thisthe first wind farm acquisition project of IberdrolaRenovables in Bulgaria.

• Advising one of the world's biggest manufacturersand suppliers of products, installations and services inthe renewable energy sector and a leading renewableenergy producer with respect to its operations inBulgaria, including agreements with landowners inBulgaria for the installation of wind masts andregulatory services.

• Assisting SG Renewables, a subsidiary of our client SGEngineering, on their existing projects; providing themwith regulatory, employment advice, etc.

• Advised PCC DEG Renewables on the acquisition oftwo hydro power plants. Work included advice on theprolongation of two water use permits under theBulgarian Law on Waters, legal due diligence, etc.

• Advising leading international renewable companyEconcern regarding their business activities in Bulgariaand helping in drafting agreements and rebrandingissues

“Clients consider the practice ‘exceptionally good,particularly the response times’.”Legal 500 2008

Kostadin SirleshtovSofia

T +3592 921 99421

E [email protected]

Elitsa IvanovaSofia

T +3592 921 9947

E elitsa.ivanova@@cms-cmck.com

SWOT analysis ofCzech market

Strengths• Specific legislation on the promotion of the

production of electricity from RES entered intoforce on 1 August 2005.

• Entitlement to connect energy production facilitiesfrom RES to the transmission or distributionsystem.

• Guaranteed return on each unit of electricityproduced from RES for a period of 15 years aftercommissioning.

• Tax incentives – income tax and real estate taxexemptions for RES.

Weaknessess• Limited potential of RES caused by the natural

conditions prevailing in the Czech Republic.

• Slow and bureaucratic procedure (many involvedparties).

• Protests of municipalities and/or residents againstcertain renewable projects.

• Long-term orientation at the traditional energysources (coal and nuclear) in the Czech Republic.

Opportunities• Low share of electricity generation currently

produced through the use of renewable energy(4.7 % in 2007) compared with the nationalindicative targets of 8% for 2010 and 13% for 2020.

• Support of RES from State programmes and EUfunds.

• Increasing small end-users (namely households)favouring use of electricity from RES.

• Non-consolidated market in renewable projects.

Threats• Inconsistency in manner of determination of

purchase price of electricity from RES by the EnergyRegulatory Office.

• Stricter conditions relating to the connection ofelectricity generation facilities using RES to thetransmission or distribution system.

• Delay or cancellation of renewable projects due toenvironmental considerations (e.g. Natura 2000).



Key assignments• Advising a strategic investor on the proposed

investment in the first ever wind farm project in theCzech Republic. Work includes due diligence,structural advice as well as advice on the newregulatory framework.

• Advising a potential strategic investor on theproposed investment in the first major wind farmproject in the Czech Republic. The work included: duediligence, advice on transaction structure as well asadvice on the new regulatory framework.

• A global US-based power company on regulatoryreview of Czech renewable energy rules.

“They have a splendid record of success, and provideimmaculate service across the board.”Chambers Europe 2008

Radim Kotlaba Prague

T +420 296 798 830

E [email protected]

SWOT analysis ofHungarian market

Strengths• The share of renewable energy only adds up to 3.6

percent of total electricity generation which isbelow the economically exploitable potential.Hungarian government plans to raise this ratio upto 13% by 2020.

• Mandatory off-take obligations and favourablefeed-in prices.

• Due to the vast agricultural areas of Hungary thereis a considerable potential in biomass basedelectricity generation.

Weaknessess• Concerns about the dispatchability of the uniform

Hungarian grid prevent the proliferation of windenergy generation.

• Of the 600MW wind generation capacity expectedto be licensed, 330MW has been licensed already.

• Grid operators are often unsupportive ofrenewable electricity generators when it comes togrid connection.

• No special VAT or other tax relief is awarded torenewable investments.

• Environmental consciousness is still rather modestin Hungary compared to Western Europeanstandards.

Opportunities• Local authorities try to be cooperative when it

comes to renewable energy generation initiatives.

• Hungary has a significant, yet fairly unexploited,potential in electricity generation from geothermalenergy, biomass and biogas sources.

• A regime of green certificates will substitute thecurrent regime of mandatory off-take, which is amore market oriented tool.

• EU structural and cohesion funds are available.

• Competition for generation licences is likely tobecome more transparent in the close future.

• Renewable energy comprises the smallest marketshare in Hungary.

Threats• The regulations regarding renewable energy

frequently change and these changes aresometimes disadvantageous.

• The technical capacity of the Hungarian electricitygrid needs some upgrading for the development ofwind and solar electricity generation facilities



Key assignments• Advised Pannonpower in relation to the construction

of a new bio (chopped wood) fuelled power plant inthe city of Pécs (turnkey EPC contract, long termwood supply contracts, etc) and in connection withfinancing of the project.

• Advised Iberdrola Renovables on the acquisition anddevelopment of two wind parks (Mistral and Vento)in Hungary.

• Advised a major global energy company in relation torenewable energy facilities, including conductungdiligence exercise regarding a wind farm project inWestern Hungary.

• Advised Investkredit on the financing of a wind parkin Hungary.

• Advising a major energy provider on financing abioethanol power station and biofuel plant on limitedrecourse basis.

• Advised OTP Bank on a facilities agreement andsecurity agreements relating to the development of abiodiesel plant in Slovakia.

• Carrying out a due diligence exercise for Babcock &Brown in connection with various wind farm projectsin Hungary.

• Advising Raiffeisen Energy Services Ltd. on theacquisition of Hungarowind, a Hungarian companyconstructing and operating wind parks. Advised ontwo other wind park projects in Hungary

"The added value of the firm is the way in which theirpartners contribute to the deal, they become part of itand don’t just wait at the sideline to draft thedocuments” Chambers Europe

Robert HayhurstBudapest

T +36 1 505 4911

E [email protected]

Péter Simon Budapest

T +36 1 483 4829

E [email protected]

Balázs Varszeghi Budapest

T +36 1 505 4929

E [email protected]

SWOT analysis ofPolish market

Strengths• Significant RES potential (especially in relation to

wind, biomass, biogas).

• Obligation on electricity suppliers to end-usecustomers to annually redeem documentscertifying generation of electricity from RES (the“green certificates”).

• Obligation on suppliers of last resort to purchase allelectricity generated by RES connected to theelectricity grid within the area of operation of therelevant supplier of last resort.

• Until 2010, RES only cover half of their actual gridinterconnection costs; after 2010 this will onlyapply to RES of less than 5MW.

• Electricity generated from RES is exempt fromexcise tax.

• Transmission priority for energy produced from RES.

• Various exemptions for smaller RES (under 5MW),such as exemption from registration fees, stampduties and annual generation licence fees.

Weaknessess• Time consuming procedures of acquiring relevant

permits and administrative decisions.

• Lack of local zoning plans.

• Lack of clarity with relation to long term leases ofland.

• Opposition to RES projects - issues related toNATURA 2000 (governmental list vs. “shadow list”prepared by the NGOs).

• Difficulties with obtaining inter-connection.

Opportunities• RES developers enjoy other benefits, such as

subsidies from local environmental funds to financetheir projects and low-interest loans available fromthe National Fund for Environmental Protection andWater Economy as well as the Bank forEnvironmental Protection.

• Several RES investments are being currentlyimplemented and numerous other projects are inthe pipeline.

• Presence of several active local developers.

Threats• New provisions regarding the Environmental Impact

Assessment procedure and participation by publicand ecological organisations in proceedings relatedto the issuance of environmental decisions requiredfor the construction of generation facilities.

• Shortage of investment in development of the gridinfrastructure.

• Extensive final list of protected NATURA 2000 sites.

• Protests from local inhabitants, especially in relationto wind projects.



Key assignments• Advising UPC on the development of a number of

wind farms located in northern Poland.

• Advised a UK-based developer on Project Komarowo -the development of a 60MW wind farm located inthe north-western part of Poland.

• Advised an international private investor on leaseagreements and on title issues regarding severalprospective wind farm sites in northern Poland.

• Assisted REG on developing, on a project financebasis, a 50 MW wind farm in northern Poland.

• Advising AES in connection with wind farm projects,in particular advising on Polish legislation affectingrenewable energy projects and carrying out duediligence of a number of prospective wind projects.

• Advising a Czech-based international renewableenergy company, being a major regional investor, onpotential acquisition of a majority share, anddevelopment jointly with a local partner, of a windfarm project in north-western Poland.

• Advising a world leader in renewable energy on thepotential acquisition and development of wind farmprojects in the northern and western Poland.

• Advising a major international renewable energycompany on the potential acquisition and developmentof a wind farm project in western Poland.

• Advising a UK-based international renewable energycompany in connection with a wind farm project.

• Advising an Austria-based renewable energy companyoperating in CEE on the acquisition and developmentof a biomass CHP.

• Advising a renewable energy company on potentialacquisition and development of wind farm projects.

• .Providing legal services to a major Western utility inrelation to the acquisition and development, andpotential acquisition and development of wind farmprojects in Poland.

• Advising a major Germany-based internationalrenewable energy company in connection withimplementation of waste incineration plant projects.

The firm has developed expertise in renewable energysources and emissions trading and is also recognisedfor housing “probably the best environmental lawgroup in town.” Chambers Global 2007

Karolina SiedlikWarsaw

T +48 22 520 5657

E [email protected]

Tomasz Pyrkowski Warsaw

T +48 22 520 5545

E [email protected]



SWOT analysis ofRomanian market

Strengths• High RES potential (especially wind and biomass).

• National target for RES is steadily increasing (33%by 2010, 35% by 2015 and 38% by 2020).

• Combined compulsory quotas and trading of greencertificates support mechanism (1 MW = 1 greencertificate) until 2012.

• Each electricity supplier is obliged to acquire, everyyear, a specified number of green certificates.Defaulting suppliers are liable to the TSO for themaximum value of the remaining (not acquired)certificates multiplied by two.

• Generation from RES may qualify for prioritydispatch on the Day Ahead Market subject toobtaining a priority dispatch certificate.

• Operators may benefit from special promotionsystems for RES (e.g. accelerated depreciation ofinvestments in renewable energy sources).

Weaknessess• Time consuming procedures for obtaining the

necessary authorizations, licenses and permits.

• High costs of the land (if the investor intends toenter into Land Purchase and Sale Agreementswith private owners).

• There are no consistent supporting mechanisms or subsidies for the cost of interconnection to thegrid.

Opportunities• Availability of state aid for investors (a legal entity

registered in Romania is a pre-requisite for filing anapplication with the relevant authorities).

• New legislation regarding the promoting system forRES providing for following:

- Extension of term of the support mechanism(combined compulsory quotas and greencertificates) until 2030.

- New energy facilities may benefit of thesupporting mechanism for a 15 year term fromthe start of operation.

- Increased value of the green certificates.

- From 2008 until 2015 a E-RES generator thatqualifies for supporting mechanism shall receive2 green certificates/1MW and starting 2016, 1 green certificate/1MW.

Threats• Little clarity on the term and costs of mandatory

public consultations for obtaining theenvironmental approval in case of NATURA 2000sites.

• The national transmission grid needs an upgrade tosupport all the announced RES capacities that areto be built over the coming years.




Key assignments• Advised Iberdrola Energias Renovables on its

acquisition of various wind farm developments inRomania totalling over 1,000 MW.

• Advised UPC in their initiatives for capturing land forwind farm development of up to 500 MW in Romaniaand on permitting and renewable energy legalframework.

• Advising a leading Austrian renewable energy banklender on the Romanian renewable energy legalframework on an ongoing basis.

• Advising Enercap Capital Partners on its acquisition ofa wind farm development in Romania.

“Profound international and domestic knowledge.” Chambers Global

Loredana Mihailescu Bucharest

T +40 21 407 3800

E [email protected]

John Fitzpatrick Bucharest

T +40 21 407 3827

E [email protected]

Simon Dayes Bucharest

T +40 21 407 2812

E [email protected]



SWOT analysis ofRussian market

Strengths• Huge RES potential especially water, wind, tidal,

geothermal and biomass.

• Eastern Siberian part of the Russian Federation hasa huge hydro potential and perfect geographicalconditions for developing large hydro generatingschemes - 5 to 7 months of freezing-over allows tominimize the output of CH4 from reservoirs intothe atmosphere

• Capacity and production of all new projects willparticipate in the competitive Wholesale ElectricityMarket, which will be fully liberalised by 2011.

Weaknessess• Bureaucratic and slow procedures.

• Increasing construction costs.

• Complicated land (wind projects) and water usepermits (hydro).

• Too many parties involved in the decision–makingprocess and as counterparts to the investors –Ministry of Energy, Ministry of Natural Resources,Ministry of Economy, Ministry of RegionalDevelopment, Federal Grid Company, SystemOperator, electricity distribution companies, etc.

Opportunities• The State is today an active investor in the power

industry, providing for financing of the infrastructurepart of new projects out of the Investment Fund

• The program for development of small hydro-powerheld by biggest Russian hydro generating company(RusHydro) - 383 potential projects are identifiedand undergoing pre-design studies for constructionof small HPP in partnership with external investors.

• Additional legislation to the Federal Law # 35 “OnElectricity” (Amendment # 250 to the Federal Law#35) regarding usage of renewable energy sourcesis in the process of negotiations.

• The new legislation will take into consideration theexperience of the EU (“the 2020 targets” and CO2emissions).

• The new legislation will determine national targetsand the mechanism for construction of 59 GW ofinstalled capacity by 2020 from RES, with 32power plants of large, medium and small size:wind (about 20 GW), bio energy sources(approximately 5 GW), geothermal (0,3 GW), tidal(0,8 GW) and other RES.

Threats• The national transmission grid needs significant

upgrades to support all the announced REScapacities that are to be built over the next years.


• Opposition to construction of hydro schemesbecause of flooding, etc

Opportunities (con’t)

• New Law on renewable and alternative energysources will establish the markup in determiningthe price of electric power generated using RES onthe wholesale and retail markets.



Key assignments• Advising a major international energy company on a

renewable project in Southern Russia.

• Advising HydroOGK on the project for the completionof Boguchanskaya hydropower station.

• OJSC UK Volzhskiy Hydroenergy Cascade – on variedaspects of the involvement of hydro generationcompanies in the proposed ancillary services market inRussia (the project s now completed).

• Advising Iberdrola Renovables on a renewable energyproject in Krasnodar (Sounthern Russia).

“The lawyers are well plugged in,” commented oneclient; “they know what is going on and they canact on it.” Chambers Europe 2008

Natalia Kozyrenko Moscow

T +7 495 786-4000

E [email protected]

Jack Neushloss Moscow

T +7 495 786-4000

E [email protected]

SWOT analysis ofUkrainian market

Strengths• The “green tariff law” has recently been adopted by

the parliament. This law: (i) permits the sale of“renewable” electricity directly to end-consumers orregional suppliers at contractual prices; and (ii)obliges wholesale electricity market ("WEM") to buyat the “green tariff” (double wholesale electricitytariff, set by NERC) the remaining electricity, whichhas not been sold to consumers or regionaldistributors.

• The Government's target set for generation fromRES is 19% of total generation by 2030. Pursuant tothe Complex Wind Farms Construction Programmeadopted in 1997, the total capacity of wind powergeneration in Ukraine is supposed to reach 1990MW by 2010, while in the meantime it is around100MW.

• Equipment for non-traditional and renewableenergy sources is exempt from the Ukrainian VATor import duties.

Weaknessess• The local experience in renewable energy projects

is not sufficient. The lack of technology experiencein Ukraine makes the technology investment cyclelong and as a result early technology developmentmust be subsidised during early adoption, wellahead of commercialisation. So far, there are nospecial VAT benefits for sales of alternative energyor special corporate profit tax treatment for powergeneration out of the RES and the existingincentives (green certificates) for the consumers topurchase this type of electricity are not workingyet.

• The wind energy tariff calculated by the producer,is approved and checked as to its compliance tothe statutory calculation methodology by theNational Electricity Regulation Commission (NERC),which creates an uncertainty as to whether theinvestment would be approved by NERC.

Opportunities• The RES market is in its nascent stages.

• According to the recent legislation, state andmunicipal land plots, that are to be used forconstruction and operation of power stations andelectric grids, shall be leased or sold without theauction.

• The Government's targeted capacity of windpower generation in Ukraine is not likely to bereached by the State by 2010 without relying onthe help of investors. The state and localauthorities seem to be very cooperative, when itcomes to renewable energy generation initiatives,especially, given the fact that some regions ofUkraine still suffer from a lack of electricity.

Threats• All the tax preferences and privileges remain

dormant in Ukraine due to the absence of animplementation procedure and effective law onmechanisms that would support RES. The lack ofincentives, adequate regulatory framework and“gaps” in the current Ukrainian legislation onelectricity retard the development of renewableenergy in Ukraine.



Key assignments• Advising European private equity investors on various

issues of the wind power plant, which would be oneof the first privately owned in Ukraine. The workincluded: advice on regulatory, tax and real estateissues.

• Advising a UK company on a wind farm project to bedeveloped by the JV with a local partner.

“With a strong dedication to the CEE market, the firmbenefits from an extensive network and the new teamprovides the firm with a particular strength in energyand oil.” Chambers and Partners 2008

Inna Saakova Kyiv

T +380 44 391 3377

E [email protected]

Vitaliy Radchenko Kyiv

T +380 44 391 3377

E [email protected]

Christina Maciw Kyiv

T +380 44 391 3377

E [email protected]

Contacts

Vivek Gambhir CEE and Emerging Markets

T +44 (0)20 7367 2985

E [email protected]

Andrzej Blach Head of CEE Energy & Projects

T +44 (0)20 7367 5509

E [email protected]

For further information on issues raised in this material, please contact the individualcontributors, or alternatively:

“In conclusion, CMS Cameron McKenna isproviding its clients with expert, commerciallyfocused advice – something which most firms

claim to do but many fail to deliver”External industry report

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